Stablecoins and Financial Stability: A Risk Leader’s Guide

Stablecoins and Financial Stability: A Risk Leader’s Guide
March 3, 2026 6 mins

Stablecoins and Financial Stability: A Risk Leader’s Guide

Stablecoins and Financial Stability: A Risk Leader’s Guide

Stablecoins are quietly embedded in how money moves across organizations through vendors, payments, and customers. Understanding where they touch your business helps risk leaders turn hidden into operational control and efficiency.

Key Takeaways
  1. Exposure often comes indirectly. Even if your organization does not hold stablecoins directly, vendors, payment flows, and customers can create risk.
  2. The risk is operational and financial, not speculative. Stablecoins intersect with treasury, counterpart, and operational risk through settlement, liquidity, and third-party dependencies.
  3. Visibility enables control. Mapping stablecoins in your processes helps assign ownership and manage exposure using familiar risk frameworks.

The Quiet Expansion of Stablecoin Exposure

Stablecoins are designed to maintain a stable value, typically pegged (linked) to fiat currencies such as the U.S. dollar. Because of this stability, they are often used as operational infostructure rather than investment vehicles, quietly supporting payments, settlements and liquidity across vendors, platforms and treasury processes.

The GENIUS Act provides a regulatory framework for stablecoins including requirements for reserve management, redemption rights and operational reporting.

Quote icon

Even if your organization never touches stablecoins directly, they may already be moving through vendors, payment flows, or treasury processes in ways that create hidden exposures. Understanding exactly where these assets interact with your business is critical for maintaining operations and realizing the potential efficiencies of stablecoins.

Glenn Morgan
Head of Digital Assets, Aon Financial Services Group
  • Partners in Motion: Managing Vendor Exposure

    Stablecoins are increasingly embedded in the operational infrastructure of vendors including payment processors, fintech platforms, payroll providers, and digital marketplaces.

    Because these arrangements often sit several steps removed from the organization, stablecoin usage may not be obvious in contracts, service descriptions, or risk assessments. Operational or technical failures such as custody errors, smart contract glitches, or incorrect wallet addresses can create liability even when the issue originates outside your organization.

    This is where vendor risk management adds value. By understanding how partners handle stablecoins, organizations can manage exposure intentionally rather than avoiding these assets entirely. Oversight ensures partners maintain institutional-grade custody and security, have insurance covering custody, cyber, crime, and smart contract risks, and clearly define liability and flow-of-funds responsibilities in contracts. Verification of regulatory alignment adds another layer of assurance.

    Considerations for building strong vendor oversight:
    • Institutional-grade custody and security measures
    • Insurance covering custody, cyber, crime, and smart contract risks
    • Clear contractual liability and flow-of-funds responsibilities
    • Regulatory and compliance alignment including GENIUS Act provisions
  • Payments in Play: Understanding Customer Impact

    Stablecoins can affect organizations through customer payments even if conversion to fiat occurs upstream. They can also be embedded in customer business models, influencing cash flow timing, refunds, or dispute handling.

    Operational challenges vary depending on payment method. Direct B2B or C2B payments require robust AML (anti-money laundering) and KYC (know-your-customer) processes to prevent fraud. Retail payments from multiple customers may need additional oversight from partners to screen wallets and protect against bad actors.

    The opportunity lies in clarifying responsibility and controls across the payment chain. If third parties handle custody, conversion, and settlement, organizations can focus on monitoring partner capabilities, verifying contractual safeguards, and ensuring residual exposure is intentional and managed.

    Considerations for customer-related stablecoin flows:
    • Identify where payments touch stablecoins directly or through partners
    • Confirm third parties have institutional-grade custody, security, and insurance
    • Ensure contracts define liability, refund, and dispute processes
    • Verify AML/KYC processes scale appropriately for transaction types and volumes
  • Treasury in Motion: Optimizing Liquidity and Controls

    Stablecoins are sometimes used as bridge assets to accelerate settlement, reduce friction in cross-border payments, or improve cash efficiency. While these benefits can unlock faster liquidity, they also introduce assumptions about timing, access to funds, and counterparty reliability.

    Treasury teams may rely on network availability, issuer stability, transaction volumes, redemption terms, and how stablecoins are minted or burned. Stress scenarios such as a stablecoin losing its peg, a bank run on a reserve institution, or sudden shifts in US Treasury holdings can quickly test these assumptions.

    The key is visibility and proactive oversight. Mapping where stablecoins touch treasury processes, understanding dependencies, and aligning with counterparties ensures digital assets support efficiency rather than creating gaps. Integration with existing policies, stress testing, and liquidity modeling allows treasuries to treat stablecoins as part of normal cash management while accounting for unique characteristics.

    Key treasury considerations:
    • Monitor intraday flows: stablecoin legs settle 24/7 but fiat on- and off-ramps follow traditional banking cutoffs
    • Manage prefunding or overcollateralization requirements that lock cash outside traditional liquidity pools
    • Track liquidity across multiple custodians, exchanges, and wallets to avoid fragmentation
    • Ensure finality versus reversibility risks are understood as operational, contractual, or regulatory issues can delay access
  • Counterparty Risk: Know Who You Rely On

    Stablecoin issuers and intermediaries function as financial counterparties. Their legal structures, reserve practices, and governance models can vary, creating differences in reliability and recovery expectations. Even if exposure is indirect, these partners can affect treasury and operational outcomes.

    Understanding counterparty risk helps organizations manage dependencies proactively rather than reactively. Mapping these dependencies alongside treasury and operational processes ensures that stablecoin activity enhances efficiency without introducing unexpected risk.

    Counterparty considerations:
    • Verify partner financial health, operational practices, and insurance coverage
    • Align KYC and AML policies with organizational risk standards
    • Review contractual safeguards including liability and flow-of-funds definitions
    • Monitor concentration risk across issuers, intermediaries, and networks
  • Operational Risk: Planning for Disruptions

    Stablecoin infrastructure can introduce operational risk even when your internal systems are sound. Payment delays, vendor outages, custody errors, or policy changes at third-party providers can cascade through treasury, finance, and customer processes.

    For example, delayed settlements due to blockchain congestion combined with partner policy changes can trigger reconciliation breaks and incident impacts at any time. Proactive planning helps organizations manage these risks without overreacting or avoiding stablecoins entirely.

    Operational risk considerations:
    • Identify dependencies across internal teams and third-party providers
    • Update incident response plans to include blockchain or stablecoin disruptions
    • Leverage existing vendor and treasury oversight to monitor custody, security and flow-of-funds responsibility
    • Test scenarios for settlement delays or system disruptions to ensure rapid recovery
    Turning Insight into Action

    To address underlying stablecoin risks and manage potential impacts organizations can begin by:

    1. Identifying indirect digital asset exposure across vendors, payments, and customers
    2. Testing liquidity and settlement assumptions tied to those exposures
    3. Clarifying ownership and escalation paths between risk, finance, and treasury
    4. Reviewing whether contractual and insurance arrangements reflect actual dependencies
    5. Integrating findings into operational and incident response playbooks
Take Action Now:

This approach turns hidden exposure into actionable insight, helping teams coordinate and maintain control, while unlocking the efficiency potential of stablecoins.

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General Disclaimer

This document is not intended to address any specific situation or to provide legal, regulatory, financial, or other advice. While care has been taken in the production of this document, Aon does not warrant, represent or guarantee the accuracy, adequacy, completeness or fitness for any purpose of the document or any part of it and can accept no liability for any loss incurred in any way by any person who may rely on it. Any recipient shall be responsible for the use to which it puts this document. This document has been compiled using information available to us up to its date of publication and is subject to any qualifications made in the document.

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